ATTACHMENT 2 FrankenFish How Genetically Engineered Salmon Could Hurt our Health and Environment !""#$%&'($)%*%+$,-$./$'%0121 The Food and Drug Administration is about to decide To make matters worse, the agency is likely to follow its pre- whether to unleash genetically engineered (GE) salmon into =8#$-!;#%815!#0!#)*(,!BC!:##&-!/0&!/%%#"!)*8-!+-*!)#!'(!-#%&! our food supply. This GE salmon, which is designed to grow without labeling,4 leaving consumers without a way to make twice as fast as normal salmon,1!"#$%&!'(!)*(!+,-)!.),/0-- an informed choice about the food we eat. genic” animal allowed into the U.S. food supply. But given how hard the biotechnology industry is pushing genetic The FDA is considering other proposals to commercialize manipulation for the animals we eat, it’s likely not the last. 7(0()81/%%5!<#&8+(&!/08</%-!:#,!$-(!80!/7,81$%)$,(9!%8D(!)*(! According to the rhetoric of the salmon’s creator, a company Enviropig, a GE pig designed for use on environmentally 1/%%(&!23$/4#$0)5!6(1*0#%#78(-9!)*8-!0("!+-*!8-!/!)(1*0#- damaging factory farms. Biotech corporations’ increas- %#781/%!-#%$)8#0!:#,!,(&$1807!+-*807!;,(--$,(!#0!"8%&!-/%<#09! ing control of the genetic content of our food already has creating jobs and diminishing the carbon footprint of produc- had a massive impact on crops like corn and soybeans, an ing seafood.2!4$)!/!,(=8("!#:!-18(0)8+1!%8)(,/)$,(!)(%%-!/!:/,! irresponsible experiment with agricultural production and different story, one full of downsides for the consumer, the human health that doesn’t need an encore performance with (0=8,#0<(0)!/0&!+-*807!(1#0#<8(-!)*,#$7*#$)!)*(!"#,%&>!!! animal agriculture. Unfortunately, the FDA is evaluating GE animals under a process used to approve new animal drugs, The commercialization of GE salmon could threaten public which allows the agency to make very little information pub- health, wipe out wild salmon populations, diminish biodiver- licly available until the decision has been made. sity of marine environments, and further drive the unhealthy ),(0&!#:!;,#&$1807!<#,(!#:!)*(!+-*!"(!(/)!80!#=(,1,#"&(&9! AquaBounty Technologies’ GE Atlantic salmon reportedly $0*(/%)*5!:/1)#,5!+-*!:/,<->! grows to market size in half the time of normal salmon5 by =8,)$(!#:!)*(!7(0(-!8<;%/0)(&!80)#!8)!:,#<!#)*(,!+-*>6 It is un- That’s all on top of potentially changing the quality of clear if the GE salmon could live up to its rapid-growth hype -/%<#09!#0(!#:!<#-)!;#;$%/,!+-*!80!)*(!?>@>!&8()>3 in large-scale commercial production (many other GE prod- ucts that were promoted as having dramatically increased Unfortunately, the Food and Drug Administration (FDA) ap- crop yields have failed to live up to these claims when used ;(/,-!)#!*/=(!;$)!23$/4#$0)5A-!-/%<#0!80!)*(!+0/%!-),()1*!#:! on farms7). What is clear is that GE salmon poses risks to the )*(!/;;,#=/%!;,#1(--!)#!'(1#<(!)*(!+,-)!BC!/08</%!)#!,(/1*! environment and consumer. U.S. consumers’ tables. !!!"#$$%&'%!&()*!&(+,"$*-./.0101.2.3(".456.5&7,8'-($'6.9:.;<<=1./.8'#$>#!!&(+,"$*- GE Salmon’s Impact on Human Health Beyond the enormous damage that GE salmon could cause )#!)*(!(0=8,#0<(0)!/0&!+-*807!(1#0#<8(-9!8)!/%-#!;#-(-!/! risk to human health. Long-term studies on the safety of eat- ing transgenic organisms have not been conducted, though scientists recognize and have already documented the ability of genetically engineered organisms to harm human and animal health. A New England Journal of Medicine study found that soy- beans engineered with Brazil nut proteins caused allergic reactions for consumers with Brazil nut allergies.8 In another case, a harmless protein found in certain beans, which acts as a pest deterrent, became dangerous once it was trans- ferred to a pea, causing allergy-related lung damage and skin problems in mice.9 One study showed high rat pup mortal- 8)5!80!%8))(,-!:,#<!<#)*(,-!:(&!BC!-#5!E#$,>10 Another found irregularities in the livers of rats, suggesting higher metabolic rates resulting from a GE diet.11!2!FGGH!-)$&5!:#$0&!-8708+- cant liver and kidney impairment in rats fed GE corn with the insecticidal Bt 7(0(!/0&!1#01%$&(&9!."8)*!)*(!;,(-(0)! data it cannot be concluded that GE corn MON863 is a safe product.”12 Even GE livestock feed may have some impact on consumers of animal products. Italian researchers found biotech genes in the milk from dairy cows fed a GE diet, sug- gesting transgenes’ ability to survive pasteurization.13 Long-term studies have yet to be conducted to assess hu- </0!*(/%)*!,8-D-!/--#18/)(&!"8)*!(/)807!),/0-7(081!+-*914 yet another indication of the weak process used to evaluate this technology. To date, the FDA has not done anything to clear up these questions. Critical studies used by the FDA in its analysis of the food safety of GE salmon were conducted by AquaBoun- signed for the rigors of life outside of captivity — mean that ty or its contractors.15!6*(!IJ2!(=(0!-/5-!80!8)-!/0/%5-8-9!.K,8- the GE salmon may only last long enough in the wild to pre- mary deference was given to controlled studies submitted by vent natural populations from reproducing, leading to a total 20 ABT [AquaBounty Technologies].”16 This is not good enough extinction of salmon in open waters. when the stakes are so high, especially since the studies did -*#"!)*/)!BC!-/%<#0!&8-;%/5(&!-#<(!-)/)8-)81/%%5!-8708+1/0)! AquaBounty’s promises to prevent escapes seem especially differences in its composition and nutrition.17 weak given the widespread problem of regular farmed salmon escapes from existing farms. In March of 2010, nearly 100,000 farmed Atlantic salmon escaped into the GE Salmon’s Impact on Wild Fish "8%&!)*,#$7*!#0(!*#%(!80!/!0()!/)!/!?N!+-*!:/,<>21 Glob- ally, these numbers are much higher, with an estimated 2 FrankenSalmon on the Lam million farmed salmon escaping into North Atlantic waters every year22!"*8%(!<8%%8#0-!#:!#)*(,-!(-1/;(!80)#!)*(!K/18+1>23 AquaBounty intends to sell GE salmon eggs to commercial One biotech corporation doing experimental GE breeding farms to grow out to full size, claiming that these operators in New Zealand is even suspected of accidentally releasing "8%%!,/8-(!+-*!80!1#0)/80(&!/3$/1$%)$,(!:/18%8)8(-!)*/)!%8<8)!)*(! 7(0()81/%%5!<#&8+(&!-/%<#0!(77-!80)#!)*(!"8%&924 demonstrat- 18 possibility of escape. The potential impact from escaping 807!)*(!%#78-)81/%!&8:+1$%)8(-!#:!;,(=(0)807!(-1/;(-9!(=(0!80! GE salmon could be severe, with researchers suggesting that tightly controlled, experimental settings. AquaBounty, in the /!-</%%!0$<'(,!#:!BC!+-*!(-1/;((-!1#$%&!1/$-(!(L)801)8#0!#:! environmental assessment it submitted to the FDA, acknowl- 19 wild populations in as little as 40 generations. Because of (&7(-9!.O#!-807%(!1#0)/80<(0)!<(/-$,(!1/0!'(!/--$,(&!#:! )*(8,!1#<;()8)8=(!/&=/0)/7(!/-!'879!=#,/18#$-!+-*9!BC!-/%<#0! 100% effectiveness.”25 1#$%&!#$)M1#<;()(!#)*(,!"8%&!+-*!:#,!:##&!/0&!*/'8)/)>!!4$)! the catch is that their own weak constitutions — not de- Elsewhere in GE food production, such as with soybeans Currently, non-GE farmed salmon are naturally bred for faster and corn, industry promises have failed to keep control of growth, which often means bigger appetites. Once they genetically engineered traits, causing enormous disruptions escape in the wild, they exhibit greater aggression and risk- in international food markets. The U.S. Government Ac- taking than wild species.29 This competitive pressure would 1#$0)/'8%8)5!P:+1(!:#$0&!-8L!D0#"0!$0/$)*#,8Q(&!,(%(/-(-! likely increase with GE salmon, which reportedly grow twice of GE crops from the United States by 2008. 26 As just one as fast as other salmon. example, in August 2006, the U.S. Department of Agriculture admitted that unapproved GE rice had been found in non-GE In addition to out-competing their wild cousins for food and rice stocks.27 Japan immediately halted all U.S. rice imports space, GE salmon could interfere with breeding in a vari- and Europe imposed heavy restrictions; in total, the event ety of ways, pushing wild stocks toward extinction. Added cost the U.S. rice industry $1.2 billion.28 Biotechnology cor- 1#<;()8)8=(!;,(--$,(!:,#<!BC!+-*!1/0!801,(/-(!-),(--!%(=(%-! porations do not have a track record of responsible owner- and increase mortality among the wild population, diminish- ship and control of their genetic traits, and in the case of GE ing their ability to effectively breed.30 In fact, several studies salmon, this could be particularly damaging, not only to wild -$77(-)!)*/)!/0!80=/-8#0!#:!),/0-7(081!+-*!80)#!/!0/)$,/%!+-*! +-*!;#;$%/)8#0-9!'$)!)#!)*(!(0)8,(!+-*807!80&$-),5> population could eventually lead to the extinction of both "8%&!/0&!),/0-7(081!+-*!80!)*/)!,(78#0>31 Competitive Advantage AquaBounty claims that it will test each commercial batch Because AquaBounty’s GE salmon is genetically designed of eggs it produces to ensure their sterility; however, this to eat more and grow faster, its escape into the wild would batch testing only needs to show a higher than 95 percent <(/0!)*(!80),#&$1)8#0!#:!-8708+1/0)!0("!1#<;()8)8=(!;,(-- sterility rate, meaning that the company may be producing sure on wild populations for food and space, as these large, -#<(!:(,)8%(!+-*>32 Additionally, the FDA has called Aqu- voracious transgenic salmon attempt to quell their hunger by /4#$0)5A-!1%/8<!)#!,/8-(!#0%5!-)(,8%(!+-*!.;#)(0)8/%%5!<8-%(/&- eating more and more. ing” because up to 5 percent of eggs sold for grow-out could be fertile.33 23$/4#$0)5A-!/--$,/01(-!*/,&%5!-((<!-$:+18(0)! given the severe consequences that even a small number of fertile GE salmon could have on wild populations. Disease An additional concern about escaping GE salmon is the dis- ease they could spread to wild populations. Farmed salmon, which are raised in stressful, densely crowded environments, have already been linked to the spread of disease.